FINRA Enhances Its Systems to Facilitate Member Compliance With Form U4 Recordkeeping Requirements

Summary 

Effective October 10, 2025, FINRA members may rely on the Central Registration Depository (CRD^®) system to maintain for recordkeeping purposes the Form U4 (Uniform Application for Securities Industry Registration or Transfer) filings that individuals electronically sign through FINRA’s Financial Professional Gateway (FinPro Gateway^TM).

Questions concerning this Notice should be directed to:

• Afshin Atabaki, Vice President and Associate General Counsel, Office of General Counsel, by email or (202) 728-8902; or
• Bill Swanstrom, Vice President, Credentialing, Registration, Education and Disclosure, by email or (240) 386-4731.

Background & Discussion

This Notice is part of the FINRA Forward initiative, which is intended to, among other things, modernize FINRA’s rules, guidance and processes and empower member compliance.¹ In Regulatory Notice 25-07 (April 14, 2025) (RN 25-07), FINRA specifically requested comment on ways that FINRA could: (1) reduce costs associated with, or create efficiencies for, the onboarding process for applicants seeking to become registered; and (2) address members’ recordkeeping challenges or simplify recordkeeping processes and obligations.

FINRA currently enables members to streamline the work associated with the registration process by allowing members and individuals to collaborate, complete and electronically sign a Form U4 via FinPro Gateway (FINRA E-Signature).² In addition, based on prior no-action relief issued by the staff of the Division of Trading and Markets (Staff) of the Securities and Exchange Commission (SEC), members may rely on CRD to satisfy their record retention requirements with respect to certain uniform registration form filings that do not require the registered person’s signature.³ 

As described below, FINRA has obtained additional no-action relief from the Staff to allow members to rely on CRD to satisfy their record retention requirements with respect to Form U4 filings that are electronically signed using FINRA E-Signature.⁴

Members’ Obligations to Maintain Signed Form U4 Filings

FINRA Rule 1010(c) requires members and applicants for membership to file with FINRA an initial or transfer Form U4 based on a signed copy of the form provided to the member or applicant for membership by the individual on whose behalf the form is being filed.⁵ In addition, any amendments to the disclosure information on Form U4 must be based on either a signed copy of the amended Form U4 provided to the member by the individual on whose behalf the Form U4 amendment is being filed, or the individual’s written acknowledgment that the disclosure information was received and reviewed.⁶ The rule also requires members to maintain the signed copy of the Form U4 in accordance with the requirements of Exchange Act Rule 17a-4(e)(1). Currently, members bear the costs and obligations associated with these recordkeeping requirements.

The Expanded No-Action Relief

To further simplify member compliance, FINRA has obtained no-action relief from the Staff to allow members to rely on CRD to satisfy the recordkeeping requirements under FINRA Rule 1010(c), Exchange Act Section 17(a) and Rule 17a-4 with respect to Form U4 filings that are electronically signed using FINRA E-Signature.⁷ 

Members are not required to rely on FINRA E-Signature to satisfy the requirements of Rule 1010(c).⁸ However, those members that choose to use FINRA E-Signature may also rely on CRD to maintain signed Form U4 filings to satisfy their recordkeeping requirements under FINRA Rule 1010(c), Exchange Act Section 17(a) and Rule 17a-4.

Use of FINRA E-Signature

To use FINRA E-Signature when submitting a Form U4 filing to CRD,⁹ members must:

1. ensure that the individual on whose behalf the Form U4 is being submitted has a FinPro Gateway account, which would require that the individual provide a valid personal email address;¹⁰
2. send a copy of the Form U4 filing to the individual’s FinPro Gateway account so that the individual may review, complete (as necessary) and electronically sign the completed Form U4;¹¹ and
3. complete the signature block for the firm signatory (i.e., the “Signature of Firm Representative”), review the completed Form U4 and submit the filing to CRD.¹² 

Conclusion

FINRA will continue to evaluate other ways in which it can enhance its systems to support member compliance and reduce unnecessary burdens.

Endnotes